News & Analysis as of

Ethics Bribery

Talking About Bribery in the Country Where I Bribed

I recently returned from a week in Amsterdam, addressing front-line compliance challenges, and attending several anti-corruption conferences. It was a surreal experience for me, for in 2003 I paid a “Dutch Agent approximately...more

Code of Conduct Week: Part III – Design of Your Code of Conduct

by Thomas Fox on

Today I continue my Code of Conduct exploration with Eric Morehead, Principal of Morehead Compliance Consulting. After having reviewed the legal requirement and business purpose in Part I, the structure and form of your Code...more

LRN Compliance Program Effectiveness Report: Part I (and Farewell to Chuck Berry)

by Thomas Fox on

Last week I interviewed Susan Divers, Senior Advisor at LRN Corporation, on the company’s 2016 Ethics and Compliance Program Effectiveness Report (Report). The Report was a fascinating review of the evolution of compliance...more

My China Compliance Diary

When my supervision (probation) ended in January 2017, the US District Court in DC released my passport, and I could once again travel internationally. And with that milestone, a note of thanks to all the international event...more

Judged by the Company You Keep

by NAVEX Global on

Earlier this month news broke that the venerable British automaker Rolls-Royce had settled an international prosecution alleging that the company’s third-party intermediaries bribed local officials in Asia. The company agreed...more

ISO 37001: Let’s Talk Specifics

by NAVEX Global on

Some, though certainly not all, of the dust has settled since ISO 37001 published last fall. As compliance professionals grapple with the new standard, we thought it would be interesting to use the power of social media to...more

The Real Explanation for the Record Year for FCPA Enforcement

by Michael Volkov on

All the FCPA prognosticators, predictors and paparazzi have missed the boat on understanding what happened this year – 2016, to make this a record year in FCPA enforcement. As a former public servant for over 20 years, I am...more

FCPA Predictions for 2017 (Part III of III)

by Michael Volkov on

With the new incoming administration, everyone is busy predicting major changes in DOJ FCPA enforcement. I do not share this view. Frankly, FCPA enforcement is more bipartisan than other controversial enforcement programs...more

Gluten Free Compliance

This past November, I had the pleasure of sitting down with Sean Freidlin, Marketing Manager of Compliance & Ethics at SAI Global, www.saiglobal.com  at The Little Beet Restaurant in NYC, to discuss my history with...more

The SEC’s Continuing Refinement of Internal Controls Enforcement

by Michael Volkov on

My good friend and colleague, Tom Fox, has written an interesting post on the SEC’s recent United Airlines settlement for $2.4 million for domestic bribery. As Tom has noted, the interesting aspect of the SEC’s enforcement...more

Coordinating Third Party Due Diligence and Procurement

by Michael Volkov on

Third party risk management is easily one of the most challenging risks for compliance officers. With all the attention and hype surrounding third party risk, companies have marshaled attention and resources to mitigate the...more

AAG Caldwell Touts Success of FCPA Enforcement and Pilot Program

by Michael Volkov on

In a speech last week, Criminal Division Assistant Attorney General Leslie Caldwell touted the success of the FCPA Pilot Program. AAG Caldwell outlined the success of the FCPA enforcement program, listing many of the...more

Gearing Compliance to the Tasks at Hand

I recently had the opportunity to travel to Chicago for my first SCCE Compliance and Ethics Institute (CEI), and attended a session “Keeping Compliance Simple,” which was led by Ricardo Pellafone, CEO, The Broadcat...more

Landmark SEC Decision Cites Compliance, Diligence in Decision Not to Prosecute FCPA Violations

by NAVEX Global on

In a remarkable affirmation of the value of robust compliance and due-diligence programs, the Securities and Exchange Commission last month announced that it would not prosecute a U.S. company for potential violations of the...more

Good-Bye to Arnold Palmer and Revolutionizing Compliance

by Thomas Fox on

The golfing world and the world of beverages lost one of their giants earlier this week. I, of course, refer to golfing and beverage legend Arnold Palmer. The legend around the beverage is that at dinner one evening Palmer...more

For An Effective Ethics and Compliance Program — First, Train Your Board and Senior Executives

by Michael Volkov on

Compliance professionals are familiar with the phrase “tone at the top,” but what exactly does it mean? Unlike other compliance program components, it cannot be easily formalized and implemented in a policy or procedure....more

Shareholders Will Get to Trial in Petrobras Corruption Scandal Action

by Thomas Fox on

Yesterday I wrote about what may well be the next great bribery and corruption scandal across the globe involving the Venezuelan state oil company Petroleos de Venezuela SA (PDVSA). However, the current largest corruption...more

The Ethics Advisor: It’s Getting Hot in Here

by Best Best & Krieger LLP on

Ah, summertime. Beaches, BBQs, visits with familia, ethics developments, balmy nights … Wait – ethics? Yes, it’s true. The world of ethics and conflicts of interest es muy caliente this summer, with a couple of...more

Even Though the Supremes Vacated Former Governor McDonnell’s Bribery Conviction, Don’t Even Think of Ditching Your Ethics...

by K&L Gates LLP on

The Supreme Court of the United States voted unanimously on June 27, 2016, to vacate former Virginia Governor Robert McDonnell’s conviction under the federal honest services and extortion statutes. In doing so, the eight...more

An Organizational Response to Global Compliance Challenges

The following is part II of a guest post by Alison Taylor and James Cohen. A consensus has emerged as to what an effective anti-corruption compliance program looks like – its components and success factors. At the same...more

The Damaging Myth of the Rogue Employee

by Thomas Fox on

As long as 24 years ago, Lynn S. Paine wrote about the myth of the rogue employee in the Harvard Business Review (HBR), in an article entitled “Managing for Organizational Integrity”. In this article she wrote, “executives...more

Key Findings from NAVEX Global's Third Party Risk Management Benchmark Report

by NAVEX Global on

Vendor risk management and, in particular, third party risk management has become one of the toughest issues companies face—especially after a string of high-profile compliance failures in recent years. The majority of...more

A Lesson in Compliance: Part I

You’ve been quite candid with your followers and readers about your compliance violations and subsequent jail term. One of your blog posts addressed the stark reality you experienced when you first found yourself sitting in a...more

A Teaching Moment Inside VimpelCom’s Boardroom

by Michael Volkov on

The VimpelCom FCPA settlement underscored the importance of Compliance 2.0 and the need to reform board deliberations and governance. No one can read the facts without shaking their heads and asking – what was the VimpelCom...more

Is There an Internal Ethics & Compliance Council In Us All?

The following guest post and video is by Nicole Rose, CEO and Founder, Create Training. We all know about ‘the law’, but how about the laws within us that direct our behavior and decisions? Marc Hauser, evolutionary...more

86 Results
|
View per page
Page: of 4
Cybersecurity

"My best business intelligence,
in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up using*

Already signed up? Log in here

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.
Feedback? Tell us what you think of the new jdsupra.com!